RAISING THE BAR: NRDC'S 2017 AVIATION BIOFUELS SCORECARD
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OCTOBER 2017
R: 17-10-A
REPORT
RAISING THE BAR: NRDC’S 2017
AVIATION BIOFUELS SCORECARDACKNOWLEDGMENTS NRDC thanks the Packard Foundation for the generous contributions that made this report possible. NRDC acknowledges the role of Patrick Mazza, MROC (Independent consultant) in preparing this report. The author of this report would also like to thank the following individuals for their contributions toward reviewing an early draft. Their review does not constitute an endorsement of the findings: James Beard (Policy Specialist - Energy & Climate Change, WWF-UK) Dr. Robert Malina (Professor of Environmental Economics, MIT Laboratory for Aviation and the Environment) About NRDC The Natural Resources Defense Council is an international nonprofit environmental organization with more than 3 million members and online activists. Since 1970, our lawyers, scientists, and other environmental specialists have worked to protect the world’s natural resources, public health, and the environment. NRDC has offices in New York City, Washington, D.C., Los Angeles, San Francisco, Chicago, Montana, and Beijing. Visit us at nrdc.org. NRDC Acting Chief Communications Officer: Michelle Egan NRDC Deputy Directors of Communications: Lisa Goffredi and Jenny Powers NRDC Senior Editor, Policy Publications: Mary Annaïse Heglar NRDC Policy Publications Editor: Tim Lau Design and Production: www.suerossi.com © Natural Resources Defense Council 2017
Table of Contents
Executive Summary.................................................................................................................................................4
Introduction: Assuring Aviation Biofuel Sustainability Through Third-Party Certification..................................8
2017 Aviation Biofuel Scorecard Survey Results....................................................................................................10
1: Airlines Rank in Four Groups.............................................................................................................................................10
2: Key Findings.......................................................................................................................................................................10
3: Additional Findings............................................................................................................................................................15
Conclusions and Recommendations........................................................................................................................ 21
Appendix A: NRDC 2017 Aviation Biofuel Scorecard Survey..................................................................................23
Appendix B: Scoring Methodology .........................................................................................................................26
Appendix C: Glossary of Acronyms.........................................................................................................................28
Endnotes.................................................................................................................................................................30Executive Summary
THIRD-PARTY CERTIFICATION IS CRUCIAL FOR transparency; rigorous, consistent, and performance-
GROWING A TRULY SUSTAINABLE AVIATION based requirements that address environmental and social
aspects of production; accreditation of auditors; and on-site
BIOFUELS INDUSTRY. annual audits to confirm that standard requirements are
With the 2016 Paris Accord, the world is coming together
met by producers. The RSB is the only standard in the
around the need to deeply reduce the greenhouse gases
marketplace today that fully meets these fundamental
(GHGs) that are driving dangerous climate change. Despite
thresholds. It is also the only standard that attempts to
the Trump administration’s June 2017 announcement
tackle the complex issue of indirect land use change (ILUC),
that the United States will withdraw from the accord, and
which can be caused by increasing feedstock demand. The
despite the fact that GHG reduction pledges under the
RSB Low ILUC Risk module allows certified producers
accord are insufficient to meet global warming limits set
to earn additional credit for documenting low-ILUC risks
out in the accord, the agreement still represents a vital step
for feedstocks. Thus, we consider it the gold standard of
toward meeting the critical challenge of climate disruption.1
sustainability certification.
But the Paris Accord only covers national actions, so
international transportation modes, aviation and marine Since 2013, NRDC’s Aviation Biofuel Scorecard has aimed
shipping, are left off the table. to encourage airline leadership to support the adoption of
truly sustainable biofuel through third-party certification
The aviation industry’s share of anthropogenic carbon
standards. Now in its fourth year, the Scorecard is the
dioxide emissions (those produced by human activities)
premier global measure of airlines’ progress toward this goal.
is now at 2 percent. If business continues as usual, it
will grow to 3 percent by 2050. To avoid that outcome, Airlines can leverage their significant purchasing power
the industry is taking steps to reduce GHG emissions, to promote sustainable practices throughout the biofuel
including adopting low-carbon fuels that assure significant supply chain. They can send clear market signals that
net GHG reductions. To be considered truly sustainable, production must comply with sustainability standards that
production of these fuels must also limit adverse impacts are independently audited through credible certification
on food security, land, water, air, wildlife, and ecosystems programs, in order to incentivize operators to proactively
and protect local communities, while also providing include this in their planning and operations.
socioeconomic benefits.
For our 2017 Scorecard, NRDC surveyed 38 airline
A process managed by the International Civil Aviation companies. We included all 29 airlines surveyed for the
Organization (ICAO) has developed a framework for the 2016 Scorecard, all of which have indicated a commitment
aviation sector ratified in October 2016. After many years to adopting aviation biofuels. We also included two new
of negotiation, the ICAO 39th Assembly adopted the Carbon airlines that have made biofuels announcements, an air
Offsetting Scheme for International Aviation (CORSIA), freight carrier that has reported significant biofuel use in
which is intended to meet the International Air Transport its ground fleet, and six airlines that round out the world’s
Association’s (IATA) broadly supported goal for carbon- top 20 by network capacity. We received responses from 17
neutral growth. The industry itself has come together companies, which is 2 fewer than the number responding
through the Sustainable Aviation Fuel Users Group to the 2016 survey. Therefore, the list of nonrespondents
(SAFUG) to promote low-carbon fuels produced under grew this year to 21, up from 9 in 2016, largely because we
strict standards for environmental and social sustainability. surveyed more companies.
Airline leaders understand their social license for growth
As we did last year, we grouped the responding airlines into
is contingent on reducing aviation GHGs as well as the
three categories, reflecting points earned for commitments
potential environmental and social impacts associated with
to biofuels and supply chain implementation:
the development of new aviation biofuels.
n Leading Airlines, 20 to 38 points (the maximum possible)
Sustainability certification based on third-party audits is
crucial to ensure well-rounded performance. Recognized n Advancing Airlines, 10 to below 20 points
certification systems include the Roundtable on n Basic Airlines, below 10 points
Sustainable Biomaterials (RSB), Bonsucro, the Roundtable
on Responsible Soy (RTRS), and the International Three Leading Airlines, at the tip of the spear for
Sustainability and Carbon Certification (ISCC). However, sustainable aviation biofuel commercialization, scored
not all certification standards are equal. Some of the key close together, ranging from 23 to 24.5 points. A middle
indicators of a credible certification standard include group of 10 Advancing Airlines, scoring 10.2 to 19.2
balanced governance; multi-stakeholder participation; reported a range of commitments to sustainable aviation
Page 4 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCbiofuel development. A cluster of 4 Basic Airlines, scoring Our findings suggest an aviation biofuel market that
4.5 to 6 points, have also made commitments in this appears to be maturing, judging from increases in
field, but at a lower level. We will describe important contracting and fuel purchases and several other important
distinguishing factors among the three categories later in industry milestones. However, as discussed later, British
this report. Airways and Air France/KLM pulled back from firm
commitments due to supply chain challenges, raising
To reflect a growing maturity in aviation biofuels
concerns. The next several years will show whether new
development, our 2017 survey and Scorecard raised the
technologies can be commercialized to produce affordable
bar for leadership. We gave more credit to actual usage
fuel at scale. That test will determine the level to which
and amounts of certified sustainable biofuels in airline
airlines can meet their 2020 IATA carbon-neutral goals
operations, and sought more detail on usage and purchase
with sustainably produced aviation biofuels.
commitments and supply chain development. We also
gave credit for a commitment to use specific third-party We placed the surveyed airlines into four categories. They
certification systems, such as the RSB. NRDC encourages are listed in the following box:
airlines to purchase only biofuel certified by a recognized
third-party standard, with strong preference for RSB.
TABLE 1: 2017 SCORECARD CATEGORY RESULTS
CATEGORY AIRLINE COMPANIES* SCORE
• Air France/KLM Royal Dutch Airlines
Leading Airlines —strongest range of commitments and
• Jet Blue 23–24.5
supply chain implementation. (scoring category: 20–38)
• United Airlines
• British Airlines
• Cathay Pacific Airways
• GOL
• Japan Air Lines
Advancing Airlines—range of fuel purchase commitments • Lufthansa
10.2–19.2
and actions.(scoring category: 10–to under 20) • Qantas Airways
• SAS
• South African Airways
• Virgin Atlantic Airways
• Virgin Australia Airlines
• Air New Zealand
Basic Airlines —basic level of fuel purchase commitments • Alaska Airlines
4.5–6
and actions.(scoring category: 1–to under 10) • Finnair
• Thomson Airways
• AeroMexico
• American Airlines
• All Nippon Airways
• Avianca Taca
• Air Canada
• Air China
• Cargolux
• easyJet
• Emirates
• Etihad Airways
Nonresponsive Airlines • FedEx 0
• GulfAir
• LATAM
• Lion Air
• Qatar Airways
• Ryanair
• Singapore Airlines
• Southwest
• Turkish Air
• UPS
• Westjet
*Airlines given alphabetically by cluster
Page 5 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCKEY FINDINGS Two airlines that reported commitments for biofuel use
A small group of companies are leading the aviation in 2016 pulled back in 2017, setting back supply chain
industry toward commercialization of sustainable development efforts:
aviation fuels. Notably, JetBlue jumped from the Basic n In 2016, British Airways had a firm commitment to
category in last year’s survey to join the Leading Airlines purchase 59 million liters of aviation biofuel by 2017,
with the September 2016 announcement that it would representing around 2 percent of demand at London’s
purchase 33 million gallons of blended jet fuel made from Heathrow airport. Unfortunately, the deal with the
hydro-processed esters and fatty acids (HEFA). This is supplier, Solena, collapsed, so the airline reported no
the largest airline biofuel commitment to date to purchase firm commitments this year.
jet fuel made from HEFA. It is also one of the largest
commitments for any form of sustainable aviation fuel.2 n In 2016, Air France/KLM had established targets
JetBlue, Air France/KLM Royal Dutch Airlines, and United through 2020. However, cost challenges and producer
Airlines have committed to using RSB-certified fuel. setbacks caused the airline to withdraw these targets.
Seven airline companies moved down in rank this
year. In 2016, British Airways, Cathay Pacific Airways, ADDITIONAL FINDINGS
SAS, and South African Airways were Leading Airlines. A commitment to high sustainability standards
This year they are Advancing. Alaska Airlines, Thomson, continues. All but one of our 17 respondents are members
and Air New Zealand moved from Advancing to Basic. of SAFUG, which sets forth a series of sustainability
This partly reflects the change in methodology that raises commitments and is a member of the RSB. RSB added one
the leadership bar. It also reflects industry supply chain new member in 2017, with Japan Air Lines joining South
setbacks and some reversals of commitments not to use African Airways and JetBlue. Ten airlines have explicitly
fuels derived from coal and natural gas. committed to using the RSB for third-party certification,
More airlines reported having certified fuel contracts and one will use ISCC.
in place. Six airlines reported firm contracts under RSB The airline biofuel workforce held steady. In 2017,
certification. These include JetBlue and Virgin Atlantic, which airlines reported 26.75 full-time-equivalent employees
did not have contracts last year. Lufthansa, a new survey working directly on biofuels, compared with 2016’s 24.83
entrant this year, has a contract under ISCC certification. to 26.83.
More airlines are implementing their commitments, Four airlines have made commitments to avoid using
purchasing and flying on certified fuel. This year, five liquid fuels derived from coal or fossil natural gas
airlines reported purchases that we could score, up from where possible. SAS, Qantas Airways, Virgin Australia,
two in the 2016 survey. United Airlines may soon have and JetBlue confirmed their commitments. Unfortunately,
commercial-scale deliveries of RSB-certified fuel to its Los though, Air France/KLM and Air New Zealand reversed
Angeles International Airport hub, which would bring the theirs this year. These reversals raise serious concerns
total to six. As of this writing, though, a final certification as fossil fuel–derived jet fuels are not consistent with the
decision had not yet been made. industry’s GHG emissions reduction goals.
Advancing and Basic Airlines have important Airlines are increasingly addressing ILUC emissions
distinguishing characteristics. Eight Advancing Airlines risks from biofuels. Demands for biofuel feedstock can
have commitments to purchase certified sustainable fuel. cause ILUC impacts such as large carbon releases from soil
Five of them have firm contracts in place to do so. Basic disturbance and forest clearing. We asked airlines whether
Airlines lack such commitments. Four Advancing Airlines they were developing measures to evaluate and avoid
received certified fuel this year, while no Basic Airline did. ILUC. Thirteen answered affirmatively, compared with
The number of supply chain investments has dropped. nine last year. We evaluated their answers and credited
Seven supply chain investments were reported for the 18 six, up from four last year. Moving forward, airlines should
months prior to the survey, compared with 11 reported in back up their measures to evaluate and avoid ILUC with
the 2016 survey. Due to an overlap in time frame, some independent certification through credible approaches such
investments in 2016 were also reported and counted again as the Low ILUC Risk module launched by the RSB in 2015.
in the 2017 results. All but one of the respondent airlines report public
policy engagements to promote sustainable fuels.
NRDC urges that all public policy advocacy by airlines
include strong endorsements of high sustainability
standards certified by third parties.
Page 6 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCAirlines consider biofuel an important tool to meet 4 Airlines should publicly disclose aviation biofuel volumes,
climate goals. This year, airlines expressed more GHG emissions, and sustainability certification.
optimism about the capacity of biofuel to help meet goals
5 To meet the industry’s GHG emission reduction goals,
for post-2020 carbon-neutral growth through sustainable
SAFUG and IATA should firmly commit to the RSB
fuels, more efficient airplanes, and improved air traffic
certification framework.
management. However, all respondents also see carbon
offsets as necessary to achieve that goal, and all airlines 6 Airlines should back up their measures to evaluate and
except one are considering them. avoid indirect land use change (ILUC) with independent
certification through credible approaches such as the
Low iLUC Risk module launched by the RSB in 2015.
RECOMMENDATIONS
The commercial aviation industry is leading the 7 When airport delivery systems allow, all airlines
development of low-carbon, sustainably produced fuel should establish a clear policy that prohibits the
supplies. These efforts deserve credit. By strengthening purchase of fuels from coal and fossil natural gas.
their sustainability commitments, airlines can further 8 Airlines should limit their use of forest-derived
contribute to the growth of more-sustainable fuel supplies biomass feedstocks to those that will demonstrably
throughout the transportation sector. reduce carbon emissions in the near term (relative
to fossil fuels) and will not threaten natural forest
ecosystems. Examples include sawdust and waste
To promote truly low-carbon, certified-sustainable aviation wood from sawmills that would otherwise quickly
biofuels that can help the industry meet its climate targets, decompose. Aviation biofuels should not be sourced
NRDC makes the following recommendations: from whole trees and other large-diameter wood,
which are known to be high-carbon feedstocks.
1 Airlines should publicly commit to sourcing only aviation
9 Any biofuel crediting under the CORSIA system should
biofuels that have been RSB-certified—specifying
be based on validated life-cycle carbon performance.
volume, percentage, and time line—and communicate
The methodology should also include ILUC factors
this to fuel and feedstock producers.
(unless ILUC mitigation measures are applied and
2 Airlines that have not yet publicly committed to using certified) as well as sustainability requirements
sustainable aviation biofuel should do so—specifying, consistent with the RSB.
volume, percentage, and time line where possible.
3 Airlines that do not yet have a firm contract for the
purchase of RSB-certified biofuels should explore and
secure a delivery contract at the earliest opportunity.
Page 7 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCIntroduction: Assuring Aviation Biofuel Sustainability
Through Third-Party Certification
With the 2016 Paris Accord the world is beginning to come together
around the need to drastically reduce climate-heating greenhouse gases
(GHGs).3 Despite the announced intent of the Trump administration to
withdraw the United States from the accord, and despite the fact that
GHG reduction pledges under the accord are insufficient to meet global
warming limits set out in the pact, the agreement still represents a vital
step toward mitigating dangerous climate change.4
Since the agreement only covers national actions, it takes communities—while providing socioeconomic benefits for
international transportation modes, like aviation and the latter. The industry itself has come together through
marine shipping, off the table. That leaves a lot of emissions the Sustainable Aviation Fuel Users Group (SAFUG) to
in the air. The aviation industry’s share of carbon dioxide promote low-carbon fuels produced under strict standards
produced by human activities, now at 2 percent, will grow for environmental and social sustainability. SAFUG
to 3 percent by 2050 without proactive steps. That 50% represents 28 airlines that account for 33 percent of the
increase would be the fastest percentage growth of any world’s commercial aviation fuel demand. We surveyed all
transportation sector.5 To avoid that outcome and maintain SAFUG members, of which 17 responded
a social license for growth in the face of increasing public
Sustainability certification based on third-party audits
concern over climate disruption, the industry is taking
is crucial to assure performance. Recognized systems
steps to reduce GHG emissions.
include the Roundtable on Sustainable Biomaterials (RSB),
Through the International Air Transport Association, the Bonsucro, the Roundtable on Responsible Soy, and the
aviation industry has committed to carbon-neutral growth International Sustainability and Carbon Certification
starting in 2020, and to reducing emissions 50 percent (ISCC). RSB is the only certification framework that
from 2005 levels by 2050.6 Airlines are approaching meets important thresholds for rigor, transparency, and
this from four angles: more-efficient aircraft, improved governance (see “Roundtable on Sustainable Biomaterials
airspace management, a carbon market mechanism, and Framework,” below). RSB’s Low ILUC Risk module
low-carbon fuels from non-fossil-fuel sources. In October allows certified producers to gain additional credit for
2016, the International Civil Aviation Organization (ICAO) documenting low ILUC risks.7 It is, therefore, widely
ratified a framework for the aviation sector. After many regarded as the gold standard of certifications. SAFUG
years of negotiation, the Carbon Offsetting Scheme for has adopted RSB principles as its model standard. NRDC
International Aviation (CORSIA) was adopted by the ICAO encourages airlines to leverage their market power by
39th Assembly. It is intended to meet the IATA’s 2020 goal, purchasing only biofuel certified by a recognized third-
which is broadly supported by the airline industry. party standard, with strong preference for RSB, as
reflected in the weighted scoring of our survey.
Because it is impractical to change fueling infrastructure
or jet engines, airlines are promoting development of The 2016 Scorecard recognized the Roundtable on
“drop-in” fuels, which can be switched into existing Sustainable Palm Oil (RSPO). However, we have significant
systems seamlessly. These replacement fuels must match concerns with the RSPO standard. Serious and unmitigated
the quality, performance, and energy density of fossil fuel, on-the-ground impacts continue in palm oil–producing
almost all of which today is petroleum. countries, including violation of community land rights,
conversion of biologically diverse natural forests to palm
Sustainability concerns are top considerations for airline
plantations, destruction of critical habitat for endangered
companies. Full life-cycle analysis must assure significant
and vulnerable species, and carbon emissions from the
net GHG reductions compared with fuels from fossil
disturbance of peatlands. Therefore, we do not support the
sources. New fuels must also limit adverse impacts on food
use of palm oil for fuel, and we opted to exclude it from the
security, land, water, air, wildlife, ecosystems, and local
2017 survey and Scorecard.
Page 8 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCThis report aims to encourage airline leadership to adopt sustainability standards—will incentivize operators to
truly sustainable biofuel through third-party certification proactively include this in their planning and operations.
standards. Now in its fourth year, the Scorecard is the premier
Some in the aviation industry have expressed concerns that
global measure of airlines’ progress toward this goal.
biofuels for the ground transportation sector are not held
Airline companies can play a critical role in driving to the same high standard as those in the aviation sector,
adoption of sustainable practices throughout their supply and that this will disadvantage new aviation biofuels.
chains. Biofuel operators are making long-term design, However, all biofuel should be held to high sustainability
employment, and operational decisions to optimize standards. As a potentially large biofuel consumer, airlines
production, and many are now focusing on aviation as are setting a standard for the biofuel industry as a whole.
a key market. Clear and time-bound commitments to NRDC encourages other transportation sectors that are
sourcing sustainable biofuels—including requiring that looking to adopt biofuels to follow suit.
production comply with third-party, independently audited 8
ROUNDTABLE ON SUSTAINABLE BIOMATERIALS (RSB) FRAMEWORK
The RSB’s comprehensive sustainability framework consists of 12 principles:8
1. Biofuel operations shall follow all applicable laws and regulations.
2. Sustainable biofuel operations shall be planned, implemented, and continuously improved through an open, transparent, and
consultative impact statement and management process and an economic viability analysis.
3. Biofuels shall contribute to climate change mitigation by significantly reducing life-cycle greenhouse gas emissions as
compared with fossil fuels.
4. Biofuel operations shall not violate human rights or labor rights and shall promote decent work and the well-being of workers.
5. In regions of poverty, biofuel operations shall contribute to the social and economic development of local, rural, and
indigenous people and communities.
6. Biofuel operations shall ensure the human right to adequate food and improve food security in food-insecure regions.
7. Biofuel operations shall avoid negative impacts on biodiversity, ecosystems, and other conservation values.
8. Biofuel operations shall implement practices that seek to reverse soil degradation and/or maintain soil health.
9. Biofuel operations shall maintain or enhance the quality and quantity of surface and ground water resources and respect
prior formal or customary water rights.
10. Air pollution from biofuel operations shall be minimized along the whole supply chain.
11. The use of technologies in biofuel operations shall seek to maximize production efficiency and social and environmental
performance and minimize the risk of damages to the environment and people.
12. Biofuel operations shall respect land rights and land use rights.
Page 9 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDC2017 Aviation Biofuel Scorecard survey results
1: AIRLINES RANK IN FOUR GROUPS 2017 Scorecard Results
For our 2017 Scorecard, NRDC surveyed 38 airlines. We Leading Airlines demonstrated the strongest commitments
included all 29 companies surveyed for the 2016 Scorecard, and actions to implement sustainable aviation fuel supply
all of which have indicated a commitment to adopting chains, including commitments to transparency and
aviation biofuels. We added two new airlines that made disclosure. Three airlines qualified for this category.
such commitments in 2017, Air Canada and Westjet. In Advancing Airlines showed a broad range of commitments
addition, to build a broader base for the survey, we added and actions to implement sustainable aviation fuel supply
China Eastern Airlines, China Southern Airlines, Delta, chains. They did not achieve the highest rank, but all 10 can
easyJet, Ryanair, and Turkish Air. This allowed our survey be considered genuine trendsetters.
to reflect the world’s top 20 airlines by network capacity. 9
We also invited UPS, which operates an air freight fleet and Basic Airlines have made fundamental commitments to
has made a major ground fleet biofuel commitment. sustainable aviation biofuels. At this point, these four
companies still need to follow through with purchase
We sent our survey to all of these airlines and followed up commitments for certified sustainable fuels.
with respondents, as needed, for additional information.
After the initial request, we also followed up with In 2016 we considered creating a Gold category for airlines
nonrespondents to encourage their participation in the that achieved 90 percent of total possible points. However,
survey. Unfortunately, none of the airlines that were added since no airline reached that threshold, there is no Gold
this year opted to participate. Several 2016 respondents, category this year.
including Etihad Airways, AeroMexico, and Singapore
Airlines, also declined to participate in this year’s survey.
One airline, Lufthansa, that was nonresponsive last year, 2: KEY FINDINGS
joined the 2017 survey. We received responses from The Leading Airlines have made the strongest efforts
17 companies, 2 fewer than in 2016. While the list of to implement commercial sustainable aviation biofuel
nonrespondents grew this year to 21, up from 9 in 2016, supply chains. Notably, JetBlue jumped from Basic
this was largely because we surveyed more companies. in last year’s report to Leading this year. In September
2016, it announced the largest commitment by any airline
As with last year, we grouped airlines responding to the to date to purchase jet fuel made from hydro-processed
survey into three categories: esters and fatty acids (HEFA); this was also one of the
n Leading Airlines, scoring 20 to 38 points largest commitments for any form of sustainable aviation
(the maximum possible) fuel.10 Air France/KLM made a certified fuel purchase and
supply chain investment and continued with a strong set
n Advancing Airlines, scoring 10 to under 20 points of commitments in most scoring categories. All Leading
n Basic airlines, scoring under 10 points Airlines have committed to using RSB-certified fuel.
Three Leading Airlines—at the tip of the spear for Seven airline companies moved down in rank this
sustainable aviation biofuel commercialization—scored year. This partly reflects the change in methodology that
close together, ranging from 23 to 24.5 points. The 10 raises the leadership bar; it also reflects industry supply
Advancing Airlines, scoring 10.2 to 19.2 points, report chain setbacks and some airlines’ reversed commitments
a range of commitments to sustainable aviation biofuel not to use fuels derived from coal and natural gas
development. The four Basic Airlines, scoring 4.5 to (discussed below). In 2016, British Airways, Cathay Pacific
6 points, have also made commitments in this field, Airways, SAS, and South African Airways were Leading.
but at a lower level. Later in this report, we will detail Now they are Advancing. Alaska Airlines, Thomson, and
the important distinguishing factors among the three Air New Zealand moved from Advancing to Basic.
categories. More airlines reported having contracts in place
This year we changed our methodology to reflect a growing to purchase certified sustainable fuel. Six airlines
maturity in aviation biofuels development. We gave more reported firm contracts under RSB certification, including
credit to actual usage and amounts of certified biofuels JetBlue and Virgin Atlantic, which did not have such
in airline operations, and we sought more detail on usage commitments last year. Lufthansa, a new survey entrant
and purchase commitments as well as supply chain this year, reported an ISCC-certified contract. South
development. Our scoring methodology is described in African Airways was the only airline that reported a
Appendix B. contract last year but did not have one this year. The airline
Page 10 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCTABLE 1: 2017 SCORECARD CATEGORY RESULTS
CATEGORY AIRLINE COMPANIES* SCORE
• Air France/KLM Royal Dutch Airlines
Leading Airlines —strongest range of commitments and
• Jet Blue 23–24.5
supply chain implementation. (scoring category: 20–38)
• United Airlines
• British Airlines
• Cathay Pacific Airways
• GOL
• Japan Air Lines
Advancing Airlines—range of fuel purchase commitments • Lufthansa
10.2–19.2
and actions.(scoring category: 10–to under 20) • Qantas Airways
• SAS
• South African Airways
• Virgin Atlantic Airways
• Virgin Australia Airlines
• Air New Zealand
Basic Airlines —basic level of fuel purchase commitments • Alaska Airlines
4.5–6
and actions.(scoring category: 1–to under 10) • Finnair
• Thomson Airways
• AeroMexico
• American Airlines
• All Nippon Airways
• Avianca Taca
• Air Canada
• Air China
• Cargolux
• easyJet
• Emirates
• Etihad Airways
Nonresponsive Airlines • FedEx 0
• GulfAir
• LATAM
• Lion Air
• Qatar Airways
• Ryanair
• Singapore Airlines
• Southwest
• Turkish Air
• UPS
• Westjet
*Airlines given alphabetically by cluster
had accepted delivery of biofuel from a test tobacco crop in Advancing and Basic Airlines have important
2016. It does, however, have substantial commitments to distinguishing characteristics. Eight Advancing Airlines
continue developing that supply chain. have committed to purchasing certified fuel. Five of them
have firm contracts to do so. Basic Airlines lack such
More airlines are implementing their commitments,
commitments. Four Advancing Airlines received certified
purchasing and flying on certified fuel. This year, five
fuel this year, while no Basic Airline did.
airlines earned points for purchases, up from just two last
year, Air France/KLM and SAS. This year, those two were Supply chain investments dropped. Seven supply
joined by Cathay Pacific Airways, South African Airways, chain investments tied to a certification framework were
and Lufthansa. United Airlines may soon have commercial- reported for the 18-month survey period, compared with
scale deliveries of RSB-certified fuel to its Los Angeles 11 in the 2016 survey. Due to the time frame—which
International Airport hub (bringing the total to six), but covered the 18 months up to the cutoff date of November
a final certification decision had not yet been made at the 21, 2016—there is some overlap between 2017 and 2016
time of this writing. results. Two Leading Airlines currently have investments,
Page 11 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCas do four Advancing and one Basic. Three dropped off this
year, including British Airways. The airline’s investment
AIRPORT FUEL DELIVERIES
in Solena was discontinued due to various commercial Los Angeles International Airport: United Airlines earned its
challenges as well as lack of government support ranking as a Leading Airline largely because of its advanced
mechanisms.11 Air France/KLM made a small investment, development of the supply chain to its hub at Los Angeles
but it was not related to a certification framework. Jet Blue International Airport (LAX). On March 11, 2016, United became
and Virgin Atlantic were new to the 2017 list of airlines the first U.S. airline to begin commercial-scale use of aviation
making supply chain investments. Etihad, which confirmed biofuels. First deliveries were by truck, but now biofuel is blended
an investment in the 2016 survey, did not respond this year. into the hydrant delivery system. Fuels are made from waste oils
at AltAir’s hydro-processing facility in Paramount, California, and
United has agreed to purchase 57 million liters of it over a three-
Two airlines that reported firm commitments to biofuel year period.13 As noted earlier, this fuel may soon be certified to the
use in 2016 had to pull back in 2017, reflecting supply RSB standard, but final certification had not yet been awarded at
chain difficulties. the time of this writing.
n In 2016, British Airways had a firm commitment to
United has also committed to purchasing at least 341 million liters
purchase 59 million liters of aviation biofuel by 2017,
per year over the next 10 years from Fulcrum BioEnergy, with
representing around 2 percent of Heathrow demand. But
deliveries to LAX expected to begin in 2019. In 2015 the airline
its supply deal with Solena collapsed, and the airline
announced a $30 million investment in Fulcrum—the largest
reported no firm commitments this year. However, the
publicly disclosed supply chain investment by any airline to date.
airline does state, “We have a firm board commitment
Fulcrum’s planned facility near Reno, Nevada, is slated to produce
to invest in new projects, subject to a number of
fuel from municipal solid waste.
conditions being met. The total volume should exceed
[59 million tons] as we are pursuing more than one Seattle–Tacoma International Airport: The Port of Seattle, Boeing,
project.” In September 2017, British Airways announced and Alaska Airlines cosponsored a study to identify the best
a partnership with Velocys to prepare a business case for infrastructure pathways to deliver up to 190 million liters of
a waste-to-fuel project.12 aviation biofuel annually to Seattle–Tacoma International Airport.
Delivered in January 2017, the study explored a range of options,
n In 2016, Air France/KLM aimed for a 1 percent biofuel
from a small volume over 12 to 18 months to a large volume over
share of overall fleet fuel use, if economically viable. The
2 to 10 years. Alaska Airlines aims to have a commercial supply
airline established targets of 2.4 million liters in 2015,
available at one of its hub airports by 2020. The study examined
3.5 million liters in 2016, 35.5 million liters in 2017,
delivery by pipeline, rail, barge, and truck, as well as storage,
and 118-355 million liters in 2020. However, in the 2017
blending, testing, and delivery by the airport hydrant system; it
survey, the airline stated, “KLM could not source any
also assessed costs at various stages. The study found that the
new sustainable biofuels in 2015, because there was a
best short-term option is a receiving and blending facility at the
worldwide lack of sustainable feedstock (RSB-certified).
airport tank farm, while the optimal long-term option is blending at
Also planned production facilities in Europe and United
refineries in Anacortes, Washington, the current regional source
States encountered setbacks and were not able to start
of jet fuel.14 In July 2017, SkyNRG, the Carbon War Room, and the
biojet fuel production until the first quarter of 2016. In
Port of Seattle followed up with a report by the Rocky Mountain
2015 and 2016 sustainable biofuels are hardly available
Institute on potential funding mechanisms to close the cost gap
against the conditions we need: Customers are not
between aviation biofuel and conventional jet fuel.15
willing to pay high premiums for sustainable biofuels.”
The airline, however, does have a firm contract in place Stockholm Arlanda Airport: The Fly Green Fund—organized by
for delivery of around 5 million liters from SkyNRG as SkyNRG in partnership with Swedavia, SAS, Air France/KLM,
it becomes available. SkyNRG is dedicated to developing and European Flight Service—began deliveries of RSB-certified
supply chains linking aviation biofuel producers with biofuels to Stockholm Arlanda Airport in late December 2016. The
airlines. partnership brings sustainable aviation fuels to Nordic countries
by enlisting corporate customers to purchase fuel. Swedavia, the
Because we broadened the survey list, the number of
owner and operator of Sweden’s major airport network, will be the
nonresponsive airlines grew to 21, compared with last
fund’s first corporate customer to use blends with sustainable
year’s 9. A number of these nonresponsive airlines have
certified fuels on all its company business flights.16 Deliveries to
announced engagements in aviation biofuels development.
Oslo’s airport began in January 2016 and were reported in last
But without transparent certification commitments, we
year’s Scorecard. These deliveries, however, came under criticism
cannot rate their sustainability performance. Transparency
from Greenpeace because the fuel was shipped from California.
is crucial for maintaining public good will and the social
The airport defended the shipments, saying that their transport
license to grow the aviation biofuels sector cited by many
represented only a fraction of the GHGs that would be released by
aviation industry leaders.
the equivalent amount of conventional jet fuel.17
Page 12 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCTHE TABLES BELOW SUMMARIZE RESPONSES TO THE 2017 SURVEY. LEADING AIRLINES ARE MARKED GREEN, ADVANCING
AIRLINES PURPLE, AND BASIC AIRLINES BLUE.
TABLE 2: AIRLINE COMMITMENTS TO PURCHASE CERTIFIED FUEL
Commitment to use Certified fuel Firm Certified fuel delivered Supply chain
certified fuel contract targets in past year investment
Air France/KLM Yes—RSB Yes—RSB No Yes No
Jet Blue Yes—RSB Yes—RSB Yes No Yes
United Airlines Yes—RSB No Yes No Yes
British Airways Yes—RSB Yes—RSB No No No
Cathay Pacific Airways Yes—RSB Yes—RSB No Yes No
SAS Yes—RSB Yes—RSB Yes Yes No
South African Airways Yes—RSB No Yes Yes Yes
Virgin Atlantic Airways Yes—RSB Yes—RSB No No Yes
GOL Yes—RSB No Yes No Yes
Japan Airlines Yes—RSB No Yes No No
Lufthansa Yes—ISCC Yes—ISCC No Yes No
Qantas No No No No No
Virgin Australia Airlines No No* Yes** No Yes
Alaska Airlines No No No No No
Air New Zealand No No* No No No
Finnair No No No No Yes
Thomson Airways No No No No No
*Virgin Australia and Air New Zealand do not have a firm contract but are currently in a Request For Information process seeking 200 million liters of sustainable aviation
fuel made in their home countries over a 10-year period beginning in 2020.
**Because Virgin Australia does not have a certification system in place for its firm targets, it did not earn points for this.
TABLE 3: CERTIFIED FUEL DELIVERED IN PAST YEAR
AMOUNT CERTIFICATION SYSTEM
Air France/KLM 145,000 liters from ITAKA and Amyris RSB and ISCC
SAS ~150,000 liters RSB
Cathay Pacific Airways 60,000 liters RSB and Bonsucro
South African Airways 35,000 liters RSB
Lufthansa 12,000 liters ISCC
Page 13 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCTABLE 4: AIRLINES’ FIRM TARGETS FOR AVIATION BIOFUEL USE
AIRLINE YEAR VOLUME PERCENTAGE†
JetBlue 2019 374.8 million liters over 10 years 1.2 percent
Fulcrum: at least 341 million liters per year over 10 years Fulcrum: 2.8 percent of current mainline fuel use
United Airlines 2016
AltAir: 57 million liters over 3 years AltAir: 0.2 percent
GOL 2020 50.4 million liters ~10 percent of a local airport uplift
Japan Air Lines 2020 None None
SAS 2020 None >1 percent
South African Airways* 2023 500 million liters* 50 percent of current Johannesburg uplift
Virgin Australia** 2020 100 million liters 5 percent
†Percentages are neat biofuel, not blends.
* South African Airways reported a 50-million-liter goal in 2016 and a 500-million-liter goal in 2017. When we inquired, an airline spokesperson explained that the latter
was always the goal and the 2016 figure was a reporting error.
**Because Virgin Australia does not have a certification system in place, we could not award points for these targets. They are given here for informational purposes.
TABLE 5: AIRLINE COMMITMENTS TO MONITORING AND DISCLOSURE
Does your airline publicly disclose the total volume Does your airline monitor the full life-cycle Are these full life-cycle
of aviation biofuels it uses in a year (whether or greenhouse gas emissions of biofuels it uses greenhouse gas emission figures
not it has used biofuels in the past year)? employing third-party life-cycle analysis? disclosed publicly now?
Air France/KLM Yes Yes Yes
JetBlue Airways Yes Yes No
United Airlines Yes Yes Yes
British Airways Yes Yes Yes
Cathay Pacific Airways Yes No No
GOL Yes No Yes
Japan Airlines Yes Yes No
Lufthansa Yes No No
Qantas Airways Yes Yes Yes
SAS Yes No No
South African Airways Yes No No
Virgin Atlantic Yes Yes Yes
Virgin Australia Airlines Yes Yes Yes
Alaska Airlines Yes No No
Air New Zealand No No No
Finnair Yes Yes Yes
Thomson Airways Yes No No
Page 14 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCIn developing economies, projects should improve
FUEL SUPPLY CHAIN DEVELOPMENT n
socioeconomic conditions for small-scale sustenance
JetBlue: In September 2016, JetBlue announced the largest farmers and avoid involuntary displacement of local
commitment by any airline to purchase jet fuel made from populations.
HEFA, as well as one of the largest commitments for any form of
sustainable aviation fuel. Beginning in 2019, the airline will take
n High-conservation-value areas and native ecosystems
nearly 375 million liters over 10 years at its hub at New York’s John should not be cleared to make way for jet fuel feedstock
F. Kennedy International Airport. That represents 1.2 percent of source development.22
fleet usage and around 6 percent of uptake at the airport. It will be Conservation commitments: The last commitment listed
blended as a 30 percent mix with petroleum jet fuel. The fuels will above allowed SAFUG members to earn an additional point
be sourced from natural oils that do not compete with food supply. in response to our survey question “Has your airline made a
Philadelphia-based SG Preston will produce the fuel at its plant in commitment not to use feedstocks from high-conservation-
Lawrence County, Ohio. Based on life-cycle analysis, the airline value areas and clearance of native ecosystems?” Finnair
projects fuel GHG reductions of at least 50 percent compared with was the only non-SAFUG member, but it has also made this
conventional jet fuel.18 commitment. Thus, 100 percent of 2017 survey respondents
Virgin Atlantic: This year, Virgin Atlantic reported a supply chain answered affirmatively to this key sustainability question.
investment for the first time. The investment was in LanzaTech, Certification commitments: In selecting certification
a company that is innovating a technology to convert waste systems, SAFUG members are pledged to use “criteria
carbon monoxide from steel plants into ethanol via proprietary . . . consistent with and complementary to emerging
microorganisms. The airline and company have been partnering internationally recognized standards such as those
since 2011 on applying the process to jet fuel. In September 2016, being developed by the Roundtable on Sustainable
they jointly announced production of 5,677 liters upgraded from Biomaterials.”23 SAFUG is a member of the RSB. For the
LanzaTech ethanol via the alcohol-to-jet process in collaboration 2017 Scorecard, the number of responding airlines that
with Pacific Northwest National Laboratory. Virgin Atlantic says are RSB members grew by one from last year, as Japan Air
the new fuel could reduce carbon emissions up to 65 percent Lines joined South African Airways and JetBlue. Most of
compared with standard jet petroleum.19 our respondents have explicitly committed to using RSB
South African Airways: As was also reported in 2016, South African for third-party certification. The exceptions are Virgin
Airways has made a supply chain investment in cultivation of a Australia, Qantas, Finnair, Alaska Airlines, Thomson, and
nicotine-free tobacco feedstock. The Solaris tobacco, developed Air New Zealand. Lufthansa has committed to using ISCC
by Italian company Sunchem, could provide South African farmers as its third-party certifier.
with a substitute for regular tobacco, as health concerns are The airline biofuel workforce stays steady. For the
reducing demand. The feedstock has gained RSB approval, and second year in a row, the 2017 Scorecard awarded points
airline support for development continues. South African Airways for staff devoted to biofuel adoption. Among our findings:
made tobacco oils into jet fuel at AltAir’s hydro-processing facility
n The aviation biofuel workforce has held steady, with
in California. On July 15, 2016, a 30 percent blend of that fuel was
airlines reporting 26.75 full-time-equivalent workers,
used for two test flights from Johannesburg to Cape Town. Around
compared with last year’s 24.83 to 26.83.
300 passengers flew on one flight by the airline and another by its
subsidiary, Mango. n With one exception, all respondent airlines have
assigned staff to biofuel adoption.
n Thirteen have at least one full-time-equivalent
3: ADDITIONAL FINDINGS employee, a growth of three from last year.
A commitment to high sustainability standards n Standouts were Air France/KLM at four employees and
continues. All but one of the 17 survey respondents are United and Lufthansa at three each.
SAFUG members, which is largely consistent with last year.
SAFUG members sign on to the following sustainability Four airlines have committed to eliminating liquid
commitments:21 fuels derived from coal or fossil natural gas. Some
alternative aviation fuel initiatives include coal and natural
n Jet fuel feedstock source development should not gas feedstocks as a hedge against oil price volatility and
jeopardize food or water supplies or biodiversity. supply shocks. Jet fuel derived from coal through the
n Total GHG emissions from feedstock growth, Fisher–Tropsch process, an approved ASTM pathway, has
harvesting, processing, and end use should be been delivered at South Africa’s Johannesburg Airport.
significantly reduced, compared with the emissions Jet fuels derived from unconventional sources including
associated with fossil fuels. tar sands and oil shale are already widespread throughout
conventional fuel supply chains.
Page 15 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCCoal-derived fuel produces far higher GHG emissions than with nine last year. We evaluated their answers and
petroleum.24 Natural gas–based liquids may provide a small credited six, up from four in 2016. Those were Air France/
GHG emissions decrease at best but could well increase KLM, British Airways, Cathay Pacific Airways, Qantas
emissions.25 Fossil fuels are also associated with significant Airways, United Airlines, and Virgin Atlantic. These
negative environmental impacts, including land disturbance airlines have adopted strategies explicitly based on using
and water pollution. Aviation biofuels that meet the waste feedstocks. Use of wastes and residues do not
sustainability requirements of the RSB and other credible typically replace an existing market demand, but in some
certification standards are environmentally preferable to cases they may already be used for other commercial
fossil fuel alternatives. purposes. In these cases they pose a low, but not
insignificant, risk of ILUC. Moving forward, airlines should
This was the second year the Scorecard investigated
back up their measures to evaluate and avoid ILUC with
whether airlines had publicly committed to eliminating
independent certification through credible approaches such
fuels made from coal or natural gas when airport fueling
as the Low ILUC Risk module launched by the RSB in 2015.
systems allow other options. SAS, Qantas Airways, Virgin
This approach is based on the Low Indirect Impact Biofuels
Australia, and JetBlue answered affirmatively. NRDC
(LIIB) methodology jointly developed by Ecofys, École
applauds this crucial commitment of these four airlines and
polytechnique fédérale de Lausanne (EPFL), and the World
urges the industry to adopt it generally.
Wildlife Fund (WWF).27
Air France/KLM and Air New Zealand, which responded
Intent to use the RSB Low ILUC Risk module earned credit
affirmatively last year, reversed their stance this year. We
in this year’s report. ILUC impacts occur outside of the
sought clarification but did not receive an answer from Air
direct scope of the biofuel supply chain and are therefore
New Zealand. Air France/KLM responded that “we are not
not routinely evaluated. However, an addition of the RSB
buying these type of fuels, but in certain parts of the world
Low ILUC Risk module will certify direct measures taken
such as South Africa, these fuels might be in the airport
by biofuel producers to mitigate the risk of indirect land
hydrant system, thus we automatically fly on it.”
use change impacts for specific feedstocks. Producers
We are concerned about these reversals. When fuels based can earn this credit from the RSB by documenting use of
on coal and natural gas are blended into an airport hydrant wastes and residues as feedstocks, increased yields, or
system, it may present real difficulties for airlines wishing employment of degraded and/or unused land.
to avoid them. However, while airlines may not be able
Other airlines reported participation in bodies such as
to control the fuels they receive, their commitment not
RSB, SAFUG, and ICAO’s Alternative Fuels Task Force. We
to use them when possible sends a message to airports.
could not credit these as sufficient in themselves to avert
Airlines should exert their influence with airport operators
ILUC risk. Other airlines reported that they made demands
to discourage these fuels. Fossil-derived jet fuels are not
on their suppliers or required information from them. But
consistent with the industry’s GHG emission reduction goals.
there was no clear internal decision-making mechanism or
verification process to ensure the information was acted on
AIRLINES ADDRESS INDIRECT LAND USE CHANGE or that the airline’s demands were met. Therefore, because
For the second year in a row, our survey asked airlines ILUC is such a high-risk issue, we found these answers
whether they were developing measures to evaluate and insufficient to earn credit.
avoid ILUC. Thirteen answered affirmatively, compared
NASA FINDS BIOFUELS REDUCE AVIATION PARTICLE EMISSIONS
Particle emissions from jet engines provide a surface on which ice crystals can form, producing contrails. Though still under study, contrails
are understood to impact how the atmosphere accumulates solar energy. A March 2017 NASA study found that a 50/50 blend of aviation fuel
and camelina oil–based biofuel reduced particle emissions by 50 to 70 percent. Researchers flew between 300 feet and 20 miles behind the
test aircraft, a DC-8 flying at up to 40,000 feet, to explore contrail formation. NASA aviation emissions researcher Bruce Anderson noted, “Soot
emissions are a major driver of contrail properties and their formation.” Cutting particle emissions “should directly translate into reduced ice
crystal concentrations in contrails, which in turn should help minimize their impact on Earth’s environment.”26
Page 16 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCBIOFUEL SUSTAINABILITY CHALLENGES
Throughout this report, the backdrop is the substantial challenge of producing truly sustainable biofuels. At the root of the challenge is the fact
that generating biomass for energy requires a large land base. That impinges on a range of issues around resource use, habitat loss, ecosystem
function, and competing demands on land.
With the growth of first-generation biofuels over the past several decades, these issues have come to the fore. A significant portion of the U.S.
corn crop is used to make ethanol fuel, and biodiesel demands oilseed crops. A wide range of estimates have been made regarding impacts on
food prices. But whatever the impact, public concern has pushed food security into the spotlight. The impact on people at the lower end of the
economic spectrum is a particular focus.
Cultivating and transporting biofuel feedstocks entails significant energy use and requires agricultural inputs, such as fertilizers, that
emit highly potent GHGs. This has raised questions over whether biofuels actually reduce GHG emissions, compared with their fossil fuel
equivalents. This is why life-cycle analysis is required to verify biofuel GHG performance. Related concerns are water use, which can be
substantial, habitat loss, and air and water pollution from agricultural operations.
Land use change has emerged as a pinnacle challenge in bringing sustainable biofuels to market. When natural ecosystems such as grasslands
and forests are converted to croplands, large stores of soil and plant carbon are released into the atmosphere. It is relatively simple to measure
GHG emissions from direct land use changes to create biofuel feedstock cropland. However, demands for biofuel feedstock can also cause
indirect land use change (ILUC) impacts. ILUC occurs when new market demand for a feedstock causes development of other lands to meet
existing feedstock demands. For example, creating new demand for palm oil to produce palm oil–derived fuel can prompt tropical forest clearing
for new palm plantations to meet demands for palm oil used in food markets. Calculating ILUC effects involves use of agricultural, forestry, and
economic models to develop best estimates of the net GHG emission impacts.
ILUC has become a key biofuel sustainability measure since the concern emerged around a decade ago. ILUC emissions are factored into the
U.S. Renewable Fuel Standard, which sets life-cycle GHG emissions standards for credit under the standard. California’s Low Carbon Fuel
Standard also mandates ILUC calculations. Computer-based scenario modeling on which these calculations rest can produce widely varied
results depending on initial assumptions.29
SAFUG GLOBAL PRINCIPLES FOR ADDRESSING
INDIRECT LAND USE CHANGE IN GOVERNMENT POLICY
1. To promote a readily available supply of [biofuels], government policies should only incentivize the development and use of fuels that meet
strong sustainability criteria, which actively protect against ILUC and other social and environmental risks.
2. Any feedstock has the potential to have deleterious impacts on the environment, including ILUC, depending on where the production is set
up and the performance of the farming practices. As the feedstock type in itself does not necessarily determine the sustainability profile of a
fuel, the emphasis should be first and foremost on the independently certified sustainability profile of the fuel in question and not simply the
feedstock type.
3. Because of the potential negative impact, Indirect Land Use Change (ILUC) must be addressed in government policies promoting the
production of sustainable fuels, and decision makers should consider mechanisms to lower the contribution of high ILUC risk biofuels and
create incentives for sustainable fuels that have been certified as low risk of ILUC.
4. Any legislation addressing ILUC should consider the possibility of project-level mitigation approaches, including, but not limited to, the
Low Indirect Impact Biofuels (LIIB) methodology currently under development by Ecofys, École polytechnique fédérale de Lausanne, and
the World Wildlife Fund (WWF). We encourage government leaders and policymakers to support the development and adoption of such
standards as one practical and cost-effective way to stimulate production of sustainable fuels that have low risk of ILUC, as well as to look
for the right opportunities to incorporate such methodology into existing certification protocols. Given the evolving understanding of ILUC,
any legislation addressing ILUC should include sufficient flexibility for future solutions and should not unreasonably hinder the progress of
existing sustainable fuel development efforts.
5. Some feedstock types, e.g. residual municipal waste, waste liquids and gases, have no negative ILUC impacts. However, regulatory schemes
that privilege certain crop-derived feedstocks without sustainability criteria, including ILUC, could cause negative environmental outcomes
and should be discouraged.
6. Consequently, any regulatory scheme to address ILUC and other sustainability measures should be applied equitably and consistently to all
feedstocks and processes, regardless of end use and country of origin.31
Page 17 RAISING THE BAR: NRDC’S 2017 AVIATION BIOFUELS SCORECARD NRDCYou can also read
